48. The following section is inserted after section 848A of the Principal Act:

“Tax treatment of return of value on certain shares

848AA. (1) In this section—

‘company’ means Vodafone plc;

‘relevant legislation’ means Part 26 of the Act of the British Parliament entitled the Companies Act 2006;

‘return of value’ means the special dividend paid in respect of fully paid bonus C shares issued to shareholders in the company in accordance with the terms of a return of value and related share consolidation, provided for by means of a scheme of arrangement under the relevant legislation, and which was completed by the company on or about 21 February 2014.

(2) Notwithstanding any other provision of this Act, the receipt by an individual who is a shareholder in the company of a return of value in an amount of not more than €1,000, shall be deemed, for the purposes of capital gains tax, to be the receipt of a capital sum derived from the individual’s ordinary shares in the company and not to be income, unless the individual elects to have that return of value treated as income.

(3) An election referred to in subsection (2) to have a return of value treated as income shall be regarded as made by an individual by including the return of value as income in a return for the year ended 31 December 2014, required to be delivered under section 879 or 959I, as appropriate.”.